(A) Disclosure Pursuant to Rule 26(a)(1) and (2).
Disclosures shall be made in the manner set forth in Fed.R.Civ.P. 26(a)(1) and
(2), except to the extent otherwise stipulated by the parties or directed by order of the Court.
Disclosure of documents and electronically stored information pursuant to Rule 26(a)(1)(A)(ii)
shall be made by providing a copy to all other parties, except as otherwise ordered by the Court.
Electronically stored information shall be disclosed in a form or forms in which it is ordinarily
maintained or in a form or forms that are reasonably usable. A party need not disclose the same
electronically stored information in more than one form.
(B) Timing and Sequence of Discovery.
Discovery shall commence in accordance with Fed.R.Civ.P. 26(d), except to the
extent otherwise stipulated by the parties or directed by order of the Court.
(C) Model Civil Protective Order
The Eastern District has approved a Model Civil Protective Order (MOED-
0071). Where the parties jointly request a protective order in the form of the Model Civil
Protective Order, the Court may presume good cause exists for the entry of that Order under
Federal Rule of Civil Procedure 26(c). The existence of an approved Model Civil Protective
Order shall not limit the ability of any party to seek a protective order in any other form where
good cause exists under Rule 26(c). Where a proposed protective order differs from the Model
Civil Protective Order, the Court may require the movant to explain the basis for any
differences between the movant’s proposed order and the Model Civil Protective Order and/or
provide a redlined copy reflecting those differences.
(Amended June 12, 2001, effective August 1, 2001; Amendment to Paragraph (A) adopted April 9, 2007, effective May 14, 2007;
Amended October 8, 2009, effective December 1, 2009; Amended October 1, 2025, effective December 15, 2025)
